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Case 1:15-cv-07433-LAP Document 1320-15 Filed 01/03/24 Page 21 of 27 log Privilege Doc 1D EmailSent Date _|Email From [Email To icc Address Subject Matter {Type of Privilege [Action Page Count | Type Attorney Client/joint ldefense/commo 1 interest/work 123| 9/21/2015 14:51 _| Virginia Giuffre smecawley@BSFLLP.com [Email chain with Giuffre and McCawley re potential legal action. [product Withheld 1 msg Plaintiff has objected that Defendant's requests are overly broad and unduly burdensome, as individually logging all privileged responsive documents would be overly burdensome. Plaintiff contends that requests targeting such privileged information are not reasonably calculated to lead to the discovery of admissible evidence, are not important to resolving the issues, are not relevant to any party's claim or defense, are not proportional to the needs of the case, and creates a heavy burden on Plaintiff that outweighs its benefit. Therefore, Plaintiff has employed categorical logging pursuant to Local Civil icginia Giuttre, Brad Rule 26.2(c). Correspondence re: Jane Doe #1 and Jane Doe #2 erein on he Bra i lv. United States ("CVRA case"), Case no. 08-80736-CIV-Marra, wards, PaulCassell, | pending in the Southern District of Florida. Documents withheld Brittany Henderson (and | Virginia Giuffre, Brad : Her pursuant to the privileges asserted included communications ther, Sigrid MeCawey, Edwards, Paul Cassell, ‘ from Ms. Giuffre to the attorneys listed seeking legal advice Meredith Schultz, Oavid Brittany Henderson, Sigri related to the CVRA case, communications from the attorneys Boies, Jack Scarola, Stan |McCawley, Meredith to Ms. Giuffre giving legal advice or giving attorney mental Pottinger, Ellen Schultz, David Boies, Jack : ‘ , impressions related to the CVRA case, communications sending Brockman, Legal Scarola, Stan Pottinger, Ellen lor attaching attorney work product related to the CVRA case, Assistants, Professionals |Brockman, Legal Assistants, , |AC Privilege and Approx. 1.3K [and/or communications sending or attaching client revisions to retained by attorneys to [Professionals retained by Work docs attorney work product related to the CVRA case, and Emails, letters, and aid in the rendition of attorneys to aid in the , Product/joint overlapping lcommunications re evidence. other communications |legal advice and rendition of legal advice and ldefense/commo with other 125 | from 2011-Present_ representation representation n interest Withheld cases Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated May 27, 2016